This Privacy Policy describes how Bond Trust (“we”/“our”/“us”) collects, uses and shares the data that you provide to us and the information we collect in the course of operating our business and our websites.

Bond Trust treats all matters relating to personal data with the utmost importance, and is required to strictly comply with the requirements of the Data Protection (Jersey) Law 2018.

This policy provides information on how we collect, use or disclose your personal data. For any enquiries relating to personal data, please contact the Bond Trust Data Manager.

We may revise this policy at any time. This policy can be found on our website at: www.bond-trust.com. You are expected to check this page from time to time to take notice of any changes we make as they will affect you.

The Personal data that we collect and where we obtain it

“Personal data” (“data”/“information”) is any information that can be used to identify you or that can be associated to you and which we have in our possession or control.

The personal data that we process may include:

• Basic information such as your name, your title or position, and relationship to other people.
• Contact Information, such as your postal address, email addresses and phone number(s).
• Financial information such as payment-related information, for example bank account details, source of funds, source of wealth, income or savings.
• Identification and background information provided by you or collected as part of our business acceptance processes.
• Personal information and background information provided to us by or on behalf of you or generated by us in the course of providing services to you, which may include special categories of data.
• Any other information identifiable to you which you may provide to Bond Trust
• Publicly available data.

Personal data provided by you

We will process personal data that you give to us, email us or provide us through various other channels as follows.

In connection with our provision of trust services

If you are a client of Bond Trust you will have provided us with personal data, or an intermediary may have. If you are not a client we may collect or receive your personal information because you are involved with one of our client matters.

Recruitment application

When you apply for a role with us you may provide us with your full name, date of birth, nationality, education and qualification details, your gender, your CV, photograph, passport details, marital status, residential status, home address and home telephone number, mobile telephone number and other details set out in your recruitment application.

Data that we may otherwise collect

We will collect data about when you use our services or when we correspond with you. We use technologies to collect and store data when you visit our websites, for example your IP address and your geographic location, browser type, the operating system and version that you use and the content you view on our website.

Data that we obtain from other sources

In connection with our provision of trust or company administration services

If we collect or receive your Personal Data in the context of our provision of trust or company administration services, we may receive data from third parties such as your employer, other parties relevant to the services we are providing, and others such as regulators and authorities. This data may include your name, contact details, employment details and other information relevant to the services that we are providing. Information and other details about you may be provided to us by a third party that provides background screening services to Bond Trust.

Recruitment application

If you apply for a position, we may collect personal data relating to past employment, qualifications and education, references from third parties, police checks, past employment history and other details about you will be provided to us by a third party that provides background screening services to Bond Trust.

How we use the Data that we collect

We may use your data:

• To provide services to our client.
• Where you have provided information as part of a recruitment process, to review and process your job application.
• To comply with legal and regulatory obligations.
• To establish, exercise or defend our legal rights, or for the purpose of legal proceedings.
• For our legitimate business interests, such as undertaking business research and analysis.
• To look into any complaints or queries you may have.
• To prevent and respond to potential fraud or illegal activities.

Grounds for using your personal data

We rely on the following legal grounds to process your personal data:

Performance of a Contract: We may need to collect and use your data to enter into a contract with you or to perform our obligations under a contract with you, such as the provision of our services.

Legitimate Interests: We may use your personal data for our legitimate interests.

Compliance with a law or regulation: We will use your personal data as necessary to comply with applicable laws and/or regulations.

Consent: If we require your consent to use your personal data outside of the above grounds, we will seek your consent which you can later withdraw by contacting the Data Manager.

Personal data shared with third parties

Your personal information may be transferred to locations outside of Bond Trust for the purposes described above. This may include:

Third party agents/suppliers or contractors, bound by obligations of confidentiality, in connection with the processing of your data for the purposes described in this policy. This may include but is not limited to IT and communications service providers.

Third parties relevant to the services we provide. This may include but is not limited to, counterparties to transactions and/or litigation, other professional service providers, regulators and authorities.

To the extent required by law, regulation or Court order; If we are under a duty to disclose your personal data in order to comply with any legal obligation.

Keeping your data and personal data security

How long we hold your personal data will depend on:

• The purpose for which we are using your data. We will need to keep the data for as long as is necessary for the relevant purpose.
• Our legal obligations - laws or regulations may set a minimum period for which we have to keep your personal data.

We ensure that the personal data is subject to appropriate security measures.

Your rights

You have a number or legal rights in relation to the personal information that we hold about you and you can exercise your rights by contacting the Bond Trust Data Manager.

These rights include:

• The right to request information regarding the processing of your personal data and access to your personal data held by us.
• The right to request that we correct your personal data if it is deemed inaccurate or incomplete.
• The right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your data but we are legally obliged and/or entitled to retain it.
• The right to object to, or request that we restrict our processing of your personal data in certain circumstances. There may be circumstances where you object to or ask us to restrict our processing of personal data but we are legally entitled and/or obliged to refuse that request.
• The right to request the personal data we hold in a structured, commonly used and machine-readable format in a timely manner.
• The right to request that we transmit your data to a third party where this is technically feasible.
• The right to withdraw consent, although in some instances it may be lawful for us to continue processing without your consent if we provide another legitimate reason (other than consent).
• The right to lodge a complaint with the Jersey Data Protection Authority, if you think any of your rights have been infringed by Bond Trust.
• Note there may be circumstances in which we may refuse requests for access to copies of your personal data. In particular, data that is subject to legal professional privilege will not be disclosed other than to our client and as authorised by our client.

Your existing data at present

• In order to protect your interests and maintain your records, we will continue to hold your file for an appropriate period.
• If you do not wish us to do so, then please contact the data manager, and we will consider your request to withdraw consent alongside our regulatory and legal obligations to maintain certain data.

Bond Trust Data Manager: Sue Powell

Email: sue.powell@bond-trust.com

Address: 4 Bond Street, St Helier, Jersey JE4 5QR

Telephone: +44 (0)1534 480403